1
Quality Payment Program Year 3
Session 44, February 12, 2019
Molly MacHarris, MIPS Program Lead, CMS
Elizabeth S. Holland, Senior Technical Advisor, CMS
2
Molly MacHarris, MIPS Program Lead, CMS
Elizabeth S. Holland, Senior Technical Advisor, CMS
Have no real or apparent conflicts of interest to report.
Conflict of Interest
3
This presentation was prepared as a tool to assist providers and is not intended to grant
rights or impose obligations. Although every reasonable effort has been made to assure
the accuracy of the information within these pages, the ultimate responsibility for the
correct submission of claims and response to any remittance advice lies with the
provider of services.
This publication is a general summary that explains certain aspects of the Medicare
Program, but is not a legal document. The official Medicare Program provisions are
contained in the relevant laws, regulations, and rulings. Medicare policy changes
frequently, and links to the source documents have been provided within the document
for your reference.
The Centers for Medicare & Medicaid Services (CMS) employees, agents, and staff
make no representation, warranty, or guarantee that this compilation of Medicare
information is error-free and will bear no responsibility or liability for the results or
consequences of the use of this presentation.
Disclaimer
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Learning Objectives
Quality Payment Program Overview
Quality Payment Program Year 1 (2017) Participation Results
Merit-based Incentive Payment System (MIPS) Year 2 (2018)
Data Submission
MIPS Overview
Final Rule for Year 3 (2019) - MIPS:
Eligibility
Reporting Options and Data Submission
Performance Categories
Additional Bonuses, Performance Threshold, and Payment
Adjustments
Quality Payment Program Help & Support
Presentation Overview
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1. Highlight Quality Payment Program Year 1 (2017) performance
data
2. Outline Year 2 (2018) MIPS data submission deadlines and
resources
3. Identify key policy changes for the third year (2019) of the
Quality Payment Program
4. Summarize eligibility, reporting, and data submission
requirements for MIPS in 2019
5. Provide an overview of available resources and no-cost technical
assistance
Learning Objectives
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Quality Payment Program Overview
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The Medicare Access and CHIP Reauthorization Act of 2015
(MACRA) requires CMS by law to implement an incentive program,
referred to as the Quality Payment Program:
Quality Payment Program
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Quick Tip: For additional information on the Quality Payment
Program, please visit qpp.cms.gov
Quality Payment Program
Considerations
Improve beneficiary outcomes
Increase adoption of
Advanced APMs
Improve data and
information sharing
Reduce burden on clinicians
Maximize participation
Ensure operational excellence
in program implementation
Deliver IT systems capabilities that
meet the needs of users
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MIPS: Quick Overview
Comprised of four performance categories
So what? The points from each performance category are added together to give you
a MIPS Final Score
The MIPS Final Score is compared to the MIPS performance threshold to determine if
you receive a positive, negative, or neutral payment adjustment
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MIPS: Terms to Know
As a refresher…
TIN (Taxpayer Identification Number)
Used by the Internal Revenue Service to identify an entity, such as a group
medical practice, that is subject to federal taxes
NPI (National Provider Identifier)
10-digit numeric identifier for individual clinicians
TIN/NPI
Identifies the individual clinician and the entity/group practice through which
the clinician bills services to CMS
Performance
Period
Also r
eferred to as…
Corresponding
Payment Year
Corresponding
Adjustment
2017 2017 “TransitionYear 2019 + or - 4%
2018 “Year 2” 2020 + or - 5%
2019 “Year 3” 2021 + or - 7%
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Quality Payment Program
Year 1 (2017) Participation Results Review
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*Clinicians are identified under the Quality Payment Program by their unique Taxpayer Identification Number/National
Provider Identifier Combination (TIN/NPI)
QPP Year 1 (2017) Performance Data
Payment Adjustments
General Participation in
2017:
1,057,824 total MIPS
eligible clinicians* received
a MIPS payment
adjustment (positive,
neutral, or negative)
1,006,319 total MIPS
eligible clinicians reported
data and received a
neutral payment
adjustment or better
99,076 total Qualifying
APM Participants (QPs)
52 total number of Partial
QPs
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QPP Year 1 (2017) Performance Data
Mean and Median National Final Score
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QPP Year 1 (2017) Performance Data
Mean and Median Final Scores by Submitter Type
*An individual is a single TIN/NPI; a group is two or more NPIs (including at least
one MIPS eligible clinician) billing under a single TIN. The “groups” column
includes APM entity groups.
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QPP Year 1 (2017) Performance Data
Mean and Median Final Scores for Large, Small, and Rural Practices
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Merit-based Incentive Payment System (MIPS)
Year 2 (2018) Data Submission
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April 2, 2019 is the 2018 MIPS data submission deadline.
There are two exceptions specific to the Quality performance
category:
Clinicians who report Quality measures via Medicare Part B
claims submit their performance data throughout the 2018
performance period (January 1 December 31, 2018)
Groups, virtual groups, and Accountable Care Organizations
reporting Quality measures through the CMS Web Interface can
submit their data between January 22 and March 22, 2019
2018 MIPS Data Submission: Key Dates
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Submitting 2018 through the QPP website:
Sign into the QPP website using your HARP credentials:
https://qpp.cms.gov/login
Submit your 2018 data for/attest to the Quality, Promoting
Interoperability, and Improvement Activities performance
categories
2018 MIPS Data Submission: How to
Submit Data
TIP: You can submit and update your data throughout the
submission period. Your data is automatically saved and clinician
records are updated in real-time. This allows you to come back at
a later time without losing any of the data.
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Easily submit and score QPP data in real-time via API:
Supports cross-origin resource sharing, allowing you to interact
securely with the API from a client-side web application
API responses can be returned in JSON or XML, including errors
Explore and Integrate with the Submissions API using:
Interactive Documentation
Developer Preview Environment
Stay Up to Date:
QPP APIs Google Group
2018 MIPS Data Submission: API
Documentation
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Visit the QPP Resource Library to access 2018 data submission
resources: https://qpp.cms.gov/about/resource-library
Resources include:
2018 Data Submission FAQs
2018 Data Submission User Guide
2018 Data Submission Demo Videos
2018 CMS Web Interface User Guides, Templates, Data
Dictionary, and more
2018 QPP Access User Guide and Demo Videos about the new
HARP System
2018 MIPS Data Submission:
Resources
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MIPS Overview
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MIPS: Quick Overview
Combined legacy programs into a single, improved program.
Physician Quality Reporting System
(PQRS)
Value-Based Payment Modifier (VM)
Medicare EHR Incentive Program (EHR)
for Eligible Professionals
MIPS
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MIPS: Quick Overview
Comprised of four performance categories
So what? The points from each performance category are added together to give you
a MIPS Final Score
The MIPS Final Score is compared to the MIPS performance threshold to determine if
you receive a positive, negative, or neutral payment adjustment
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MIPS: Timeline
Deadline for
submitting data is
March 31, 2020
Clinicians are
encouraged to
submit data early
CMS provides
performance feedback
after the data is
submitted
Clinicians will receive
feedback before the
start of the payment
year
MIPS payment
adjustments are
prospectively applied to
each claim for service
furnished beginning
January 1, 2021
2019
Performance Year
March 31, 2020
Data Submission
Feedback
January 1, 2021
Payment Adjustment
Feedback available adjustment
submitPerformance period
Performance period
opens January 1, 2019
Closes December 31,
2019
Clinicians care for
patients and record
data during the year
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Final Rule for Year 3 (2019) MIPS
Eligibility
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MIPS Year 3 (2019) Final
MIPS Eligible Clinician Types
MIPS eligible clinicians include:
Physicians
Physician Assistants
Nurse Practitioners
Clinical Nurse Specialists
Certified Registered Nurse Anesthetists
Groups of such clinicians
Year 2 (2018) Final
MIPS eligible clinicians include:
Same five clinician types from
Year 2 (2018)
AND:
Clinical Psychologists
Physical Therapists
Occupational Therapists
Speech-Language Pathologists*
Audiologists*
Registered Dieticians or Nutrition
Professionals*
Year 3 (2019) Final
*We modified our proposals to add these additional clinician types for Year 3 as a result of the significant support we received during the
comment period
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MIPS Year 3 (2019) Final
Low-Volume Threshold Criteria
What do I need to know?
1. Threshold amounts remain the same as in Year 2 (2018)
2. Added a third element Number of Services to the low-volume
threshold determination criteria
The finalized criteria now includes:
Dollar amount $90,000 in covered professional services under
the Physician Fee Schedule (PFS)
Number of beneficiaries 200 Medicare Part B beneficiaries
Number of services* (New) 200 covered professional services
under the PFS
*When we say “service”, we are equating one professional claim line with positive allowed charges to one covered
professional service
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MIPS Year 3 (2019) Final
Low-Volume Threshold Determination
How does CMS determine if I am included in MIPS in Year 3 (2019)?
1. Be a MIPS eligible clinician type (as listed on slide 18)
2. Exceed all three elements of the low-volume threshold criteria:
Bill more than $90,000 a year in allowed charges for covered
professional services under the Medicare Physician Fee Schedule
(PFS)
AND
Furnish covered professional services to more than 200 Medicare
Part B beneficiaries
AND
Provide more than 200 covered professional services under the PFS
(New)
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MIPS Year 3 (2019) Final
Low-Volume Threshold Determination
What else do I need to know?
Clinicians who:
x DO NOT bill more than $90,000 a year in allowed charges for covered professional
services under the Medicare Physician Fee Schedule (PFS)
OR
x DO NOT furnish covered professional services to more than 200 Medicare beneficiaries
OR
x DO NOT provide more than 200 covered professional services under the PFS (New)
Are excluded from MIPS in Year 3 (2019) and do not need to participate
Remember: To be required to participate, clinicians must:
BILLING
>$90,000
AND
BENEFICIARIES
>200
SERVICES
>200
AND
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MIPS Year 3 (2019) Final
Low-Volume Threshold Determination
What happens if I am excluded, but want to participate in MIPS?
You have two options:
1. Voluntarily participate
You’ll submit data to CMS and receive performance feedback
You will not receive a MIPS payment adjustment
2. Opt-in (Newly added for Year 3)
Opt-in is available for MIPS eligible clinicians who are excluded from
MIPS based on the low-volume threshold determination
If you are a MIPS eligible clinician and meet or exceed at least one,
but not all, of the low-volume threshold criteria, you may opt-in to
MIPS
If you opt-in, you’ll be subject to the MIPS performance
requirements, MIPS payment adjustment, etc.
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MIPS Year 3 (2019) Final
Opt-in Policy
MIPS eligible clinicians who meet or exceed at least one, but not all, of the
low-volume threshold criteria may choose to participate in MIPS
Dollars Beneficiaries
Professional Services
(New)
Eligible for Opt-in?
≤ 90K ≤ 200 ≤ 200 No excluded
≤ 90K ≤ 200 > 200
Yes (may also voluntarily report or not
participate)
> 90K ≤ 200 ≤ 200
Yes (may also voluntarily report or not
participate)
> 90K ≤ 200 >200
Yes (may also voluntarily report or not
participate)
≤ 90K > 200 > 200
Yes (may also voluntarily report or not
participate)
> 90K > 200 > 200 No required to participate
MIPS Opt-in Scenarios
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MIPS Year 3 (2019) Final
Opt-in Policy - Example
Did not exceed all three elements of the low-volume threshold determination criteria,
therefore exempt from MIPS in Year 3
However…
This clinician could opt-in to MIPS and participate in Year 3 (2019) since the clinician
met or exceeded at least one (in this case, two) of the low-volume threshold criteria
and is also a MIPS eligible clinician type
Physical Therapist (Individual)
Billed $100,000 x Saw 100 patients
Provided 201 covered
professional services
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MIPS Year 3 (2019) Final
Opt-in Policy
What else do I need to know?
Once an election has been made, the decision to opt-in to MIPS would be
irrevocable and could not be changed
Clinicians or groups who opt-in are subject to all of the MIPS rules, special status,
and MIPS payment adjustment
Please note that APM Entities interested in opting-in to participate in MIPS under the
APM Scoring Standard would do so at the APM Entity level
User Research Opportunity:
If you’re interested in participating in user research for MIPS, we want to hear from
you! We encourage you to send your contact information to:
QPPUserResearch@cms.hhs.gov
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MIPS Year 3 (2019) Final
MIPS Determination Period
Low Volume Threshold Determination Period:
First 12-month segment: Sept. 1, 2016 - Aug. 31, 2017
(including 30-day claims run out)
Second 12-month segment: Sept. 1, 2017 - Aug. 31,
2018 (including a 30-day claims run out)
Special Status
Use various determination periods to identify MIPS
eligible clinicians with a special status and apply the
designation.
Special status includes:
Non-Patient Facing
Small Practice
Rural Practice
Health Professional Shortage Area (HPSA)
Hospital-based
Ambulatory Surgical Center-based (ASC-based)
Year 2 (2018) Final
Change to the MIPS Determination Period:
First 12-month segment: Oct. 1, 2017 - Sept. 30,
2018 (including a 30-day claims run out)
Second 12-month segment: Oct. 1, 2018 - Sept. 30,
2019 (does not include a 30-day claims run out)
Goal: Consolidate the multiple timeframes and align
the determination period with the fiscal year
Goal: Streamlined period will also identify MIPS
eligible clinicians with the following special status:
-
Non-Patient Facing
-
Small Practice
-
Hospital-based
-
ASC-based
Note: Rural and HPSA status continue to apply in 2019
Year 3 (2019) Final
Quick Tip: MIPS eligible clinicians with a special status are included in MIPS and qualify for special rules. Having a special status does
not exempt a clinician from MIPS.
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Final Rule for Year 3 (2019) MIPS
Reporting Options and Data Submission
36
MIPS Year 3 (2019) Final
Reporting Options
What are my reporting options if I am required to participate in MIPS?
Same reporting options as Year 2. Clinicians can report as or part of a/an:
Individual Group
2. As a Group
a) 2 or more clinicians (NPIs),
including at least one MIPS
eligible clinician, who have
reassigned their billing rights
to a single TIN*
b) As an APM Entity
1. As an Individual under a
National Provider Identifier
(NPI) number and
Taxpayer Identification
Number (TIN) where they
reassign benefits
Virtual Group
3. As a Virtual Group
made up of solo
practitioners and groups
of 10 or fewer eligible
clinicians who come
together “virtually” (no
matter what specialty or
location) to participate in
MIPS for a performance
period for a year
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MIPS Year 3 (2019) Final
Submitting Data - Collection, Submission, and Submitter Types
What do I need to know about submitting my performance data?
For Year 3 (2019), we have revised existing terms and defined additional terminology
to help clarify the process of submitting data:
Collection Types
Submission Types
Submitter Types
Why did you make this change?
In Year 2 (2018), we used the term “submission mechanism” all-inclusively when
talking about:
The method by which data is submitted (e.g., registry, EHR, attestation, etc.)
Certain types of measures and activities on which data are submitted
Entities submitting such data (i.e., third party intermediaries submitting on
behalf of a group)
We found that this caused confusion for clinicians and those submitting on behalf of
clinicians
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MIPS Year 3 (2019) Final
Submitting Data - Collection, Submission, and Submitter Types
Definitions for Newly Finalized Terms:
Collection type- A set of quality measures with comparable specifications and data completeness
criteria including, but not limited to: electronic clinical quality measures (eCQMs); MIPS Clinical
Quality Measures* (MIPS CQMs); Qualified Clinical Data Registry (QCDR) measures; Medicare
Part B claims measures; CMS Web Interface measures; the CAHPS for MIPS survey; and
administrative claims measures.
Submission type- The mechanism by which a submitter type submits data to CMS, including, but
not limited to: direct, log in and upload, log in and attest, Medicare Part B claims, and the CMS Web
Interface.
The Medicare Part B claims submission type is for clinicians or groups in small practices
only to continue providing reporting flexibility
Submitter type- The MIPS eligible clinician, group, virtual group, or third party intermediary acting
on behalf of a MIPS eligible clinician, group, or virtual group, as applicable, that submits data on
measures and activities.
*The term MIPS CQMs would replace what was formerly referred to as “registry measures” since
clinicians that don’t use a registry may submit data on these measures.
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MIPS Year 3 (2019) Final
Collection, Submission, and Submitter Types - Example
Data Submission for MIPS Eligible Clinicians Reporting as Individuals
Performance
Category
Submission Type Submitter Type Collection Type
Direct
Log-in and Upload
Medicare Part B Claims
(small practices only)
Individual
Third Party
Intermediary
eCQMs
MIPS CQMs
QCDR Measures
Medicare Part B Claims
Measures (small practices
only)
No data submission
required
Individual
-
Direct
Log-in and Upload
Log-in and Attest
Individual
Third Party
Intermediary
-
Direct
Log-in and Upload
Log-in and Attest
Individual
Third Party
Intermediary
-
Quality
Cost
Improvement
Activities
Promoting
Interoperability
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MIPS Year 3 (2019) Final
Collection, Submission, and Submitter Types - Example
Data Submission for MIPS Eligible Clinicians Reporting as Groups
Performance
Category
Submission Type Submitter Type Collection Type
Direct
Log-in and Upload
CMS Web Interface (groups of 25
or more eligible clinicians)
Medicare Part B Claims (small
practices only)
Group
Third Party
Intermediary
eCQMs
MIPS CQMs
QCDR Measures
CMS Web Interface Measures
CMS Approved Survey Vendor Measure
Administrative Claims Measures
Medicare Part B Claims (small practices only)
No data submission required
Group
-
Direct
Log-in and Upload
Log-in and Attest
Group
Third Party
Intermediary
-
Direct
Log-in and Upload
Log-in and Attest
Group
Third Party
Intermediary
-
Quality
Cost
Improvement
Activities
Promoting
Interoperability
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Final Rule for Year 3 (2019) MIPS
Performance Categories
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MIPS Year 3 (2019) Final
Performance Period
Year 2 (2018) Final
Performance
Category
Performance
Period
Quality
12-months
Cost
12-months
Improvement
Activities
90-days
Promoting
Interoperability
90-days
Year 3 (2019) Final - No Change
Performance
Category
Performance
Period
Quality
12-months
Cost
12-months
Improvement
Activities
90-days
Promoting
Interoperability
90-days
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MIPS Year 3 (2019) Final
Performance Category Weights
Year 2 (2018) Final
Performance
Category
Performance
Category Weight
Quality
45%
Cost
15%
Improvement
Activities
15%
Promoting
Interoperability
25%
Year 3 (2019) Final
Performance
Category
Performance
Category Weight
Quality
50%
Cost
10%
Improvement
Activities
15%
Promoting
Interoperability
25%
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MIPS Year 3 (2019) Final
Quality Performance Category
Basics:
45% of Final Score in 2019
You select 6 individual measures
̶ 1 must be an outcome measure
OR
̶ High-priority measure
If less than 6 measures apply, then
report on each applicable measure
You may also select a specialty-
specific set of measures
Meaningful Measures
Goal: The Meaningful Measures Initiative is aimed at
identifying the highest priority areas for quality
measurement and quality improvement to assess the
core quality of care issues that are most vital to
advancing our work to improve patient outcomes
For 2019, we are:
̶ Removing 26 quality measures, including
those that are process, duplicative, and/or
topped-out
̶ Adding 8 measures (4 Patient-Reported
Outcome Measures), 6 of which are high-
priority
Total of 257 quality measures for 2019
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MIPS Year 3 (2019) Final
Quality Performance Category
Bonus Points
Year 2 (2018) Final Year 3 (2019) Final
2 points for outcome or
patient experience
1 point for other high-
priority measures
1 point for each
measure submitted
using electronic end-to-
end reporting
Cap bonus points at
10% of category
denominator
Same requirements as
Year 2, with the following
changes:
Add small practice
bonus of 6 points for
MIPS eligible clinicians in
small practices who
submit data on at least 1
quality measure
Updated the definition of
high-
opioid-related measures
Quick Tip: A small practice is defined as 15 or fewer eligible clinicians
Basics:
45% of Final Score in 2019
You select 6 individual measures
̶ 1 must be an outcome measure
OR
̶ High-priority measure
If less than 6 measures apply, then
report on each applicable measure
You may also select a specialty-
specific set of measures
46
MIPS Year 3 (2019) Final
Quality Performance Category
Data Completeness
Year 2 (2018) Final Year 3 (2019) Final
60% for submission
mechanisms except for
Web Interface and
CAHPS
Measures that do not
meet the data
completeness criteria
earn 1 point
Small practices
continue to receive 3
points
Same requirements as
Year 2
Basics:
45% of Final Score in 2019
You select 6 individual measures
̶ 1 must be an outcome measure
OR
̶ High-priority measure
If less than 6 measures apply, then
report on each applicable measure
You may also select a specialty-
specific set of measures
47
MIPS Year 3 (2019) Final
Quality Performance Category
Basics:
45% of Final Score in 2019
You select 6 individual measures
̶ 1 must be an outcome measure
OR
̶ High-priority measure
If less than 6 measures apply, then
report on each applicable measure
You may also select a specialty-
specific set of measures
Special Scoring Considerations
Measures Impacted by Clinical Guideline Changes
CMS will identify measures for which following the
guidelines in the existing measure specification could
result in patient harm or otherwise provide misleading
results as to good quality care
Clinicians who are following the revised clinical
guidelines will still need to submit the impacted
measure
The total available measure achievement points in the
denominator will be reduced by 10 points for each
impacted measure and the numerator of the impacted
measure will result in zero points
Groups Registered to Report the CAHPS for MIPS
Survey
If the sample size was not sufficient and if the group
doesn’t select another measure, the total available
measure achievement points will be reduced by 10
and the measures will receive zero points
48
MIPS Year 3 (2019) Final
Quality Performance Category
Basics:
45% of Final Score in 2019
You select 6 individual measures
̶ 1 must be an outcome measure
OR
̶ High-priority measure
If less than 6 measures apply, then
report on each applicable measure
You may also select a specialty-
specific set of measures
Improvement Scoring
Year 2 (2018) Final Year 3 (2019) Final
Eligible clinicians must
fully participate (i.e.
submit all required
measures and have
met data completeness
criteria) for the
performance period
If the eligible clinician
has a previous year
Quality performance
category score less
than or equal to 30%,
we would compare
2018 performance to
an assumed 2017
Quality performance
category score of 30%
Same requirements as
Year 2
49
MIPS Year 3 (2019) Final
Quality Performance Category
Basics:
45% of Final Score in 2019
You select 6 individual measures
̶ 1 must be an outcome measure
OR
̶ High-priority measure
If less than 6 measures apply, then
report on each applicable measure
You may also select a specialty-
specific set of measures
Topped-out Measures
Year 2 (2018) Final Year 3 (2019) Final
A topped out measure is
when performance is so
high and unwavering that
meaningful distinctions
and improvement in
performance can no
longer be made
4-year lifecycle to identify
and remove topped out
measures
Scoring cap of 7 points for
topped out measures
Same requirements as Year
2, with the following changes:
Extremely Topped-Out
Measures:
̶ A measure attains
extremely topped-out
status when the
average mean
performance is within
the 98
th
to 100
th
percentile range
CMS may propose
removing the measure
in the next rulemaking
cycle
QCDR measures are
excluded from the topped
out measure lifecycle and
special scoring policies
50
MIPS Year 3 (2019) Final
Cost Performance Category
Basics:
15% of Final Score in 2019
Measures:
̶ Medicare Spending Per
Beneficiary (MSPB)
̶ Total Per Capita Cost
̶ Adding 8 episode-based
measures
No reporting requirement; data
pulled from administrative claims
No improvement scoring in Year 3
Measure Case Minimums
Year 2 (2018) Final Year 3 (2019) Final
Case minimum
of 20 for
Total per Capita Cost
measure and 35 for
MSPB
Same requirements as
Year 2, with the following
additions:
Case minimum of 10 for
procedural episodes
Case minimum of 20 for
acute inpatient medical
condition episodes
51
MIPS Year 3 (2019) Final
Cost Performance Category
Basics:
15% of Final Score in 2019
Measures:
̶ Medicare Spending Per
Beneficiary (MSPB)
̶ Total Per Capita Cost
̶ Adding 8 episode-based
measures
No reporting requirement; data
pulled from administrative claims
No improvement scoring in Year 3
Measure Attribution
Year 2 (2018) Final Year 3 (2019) Final
Plurality of primary care
services rendered by the
clinician to determine
attribution for the Total
per Capita Cost measure
Plurality of Part B
services billed during the
index admission to
determination attribution
for the MSPB measure
Added two
CPT codes to
the list of primary care
services used to
determine attribution
under the Total per
Capita Cost measure
Same requirements as Year
2, with the following additions:
For procedural episodes:
CMS will attribute episodes to
the clinician that performs the
procedure
For acute inpatient medical
condition episodes: CMS will
attribute episodes to each
clinician who bills inpatient
evaluation and management
(E&M) claim lines during a
trigger inpatient
hospitalization under a TIN
that renders at least 30
percent of the inpatient E&M
claim lines in that
hospitalization
52
MIPS Year 3 (2019) Final
Cost Performance Category
Episode-Based Measures Finalized for the 2019 MIPS Performance Period
Beginning with the 2019 MIPS performance period, eight episode-based measures will also
be used to evaluate cost. The eight episode-based cost measures are highlighted below.
Measure Topic Measure Type
Elective Outpatient Percutaneous Coronary
Intervention (PCI)
Procedural
Knee Arthroplasty Procedural
Revascularization for Lower Extremity Chronic
Critical Limb Ischemia
Procedural
Routine Cataract Removal with Intraocular
Lens (IOL) Implantation
Procedural
Screening/Surveillance Colonoscopy Procedural
Intracranial Hemorrhage or Cerebral Infarction Acute inpatient medical condition
Simple Pneumonia with Hospitalization Acute inpatient medical condition
ST-Elevation Myocardial Infarction (STEMI)
with Percutaneous Coronary Intervention (PCI)
Acute inpatient medical condition
53
MIPS Year 3 (2019) Final
Facility-based Quality and Cost Performance Measures
What is it?
Facility-based scoring is an option for clinicians that meet certain criteria beginning
with the 2019 performance period
CMS finalized this policy for the 2019 performance period in the 2018 Final
Rule
Facility-based scoring allows for certain clinicians to have their Quality and
Cost performance category scores based on the performance of the hospitals
at which they work
54
MIPS Year 3 (2019) Final
Facility-based Quality and Cost Performance Measures
Applicability: Individual
MIPS eligible clinician furnishes 75% or more of their covered professional services in
inpatient hospital (Place of Service code 21), on-campus outpatient hospital (POS
22), or an emergency room (POS 23), based on claims for a period prior to the
performance period
Clinician would be required to have at least a single service billed with POS code
used for inpatient hospital or emergency room
Applicability: Group
Facility-based group would be one in which 75% or more of eligible clinicians billing
under the group’s TIN are eligible for facility-based measurement as individuals
55
MIPS Year 3 (2019) Final
Facility-based Quality and Cost Performance Measures
Attribution
Facility-based clinician would be attributed to hospital where they provide services to most patients
Facility-based group would be attributed to hospital where most facility-based clinicians are
attributed
If unable to identify facility with the Hospital Value-based Purchasing (VBP) score to attribute
clinician’s performance, that clinician would not be eligible for facility-based measurement and
would have to participate in MIPS via other methods
Election
Automatically apply facility-based measurement to MIPS eligible clinicians and groups who are
eligible for facility-based measurement and who would benefit by having a higher combined Quality
and Cost score
No submission requirements for individual clinicians in facility-based measurement, but a group
would need to submit data for the Improvement Activities or Promoting Interoperability performance
categories in order to be measured as a facility-based group
56
MIPS Year 3 (2019) Final
Facility-based Quality and Cost Performance Measures
Measurement
For facility-based measurement, the measure set for the fiscal year Hospital VBP Program that
begins during the applicable MIPS performance period would be used for facility-based clinicians
Example: For the 2019 MIPS performance period (Year 3), the measures used would be those for
the 2020 Hospital VBP Program along with the associated benchmarks and performance periods
Benchmarks
Benchmarks for facility-based measurement are those that are adopted under the hospital VBP
Program of the facility for the year specified
57
MIPS Year 3 (2019) Final
Facility-based Quality and Cost Performance Measures
Assigning MIPS Category Scores
The Quality and Cost performance category scores (which are separate scores) for facility-based
clinicians are based on how well the clinician’s hospital performs in comparison to other hospitals in
the Hospital VBP Program
Scoring Special Rules
Some hospitals do not receive a Total Performance Score in a given year in the Hospital VBP
Program, whether due to insufficient quality measure data, failure to meet requirements under the
Hospital In-patient Quality Reporting (IQR) Program, or other reasons
In these cases, we would be unable to calculate a facility-based score based on the hospital’s
performance, and facility-based clinicians would be required to participate in MIPS via another
method
58
MIPS Year 3 (2019) Final
Improvement Activities Performance Category
Basics:
15% of Final Score in 2019
Select Improvement Activities and
attest “yes” to completing
Activity weights remain the same:
Medium = 10 points
High = 20 points
Small practices, non-patient
facing clinicians, and/or
clinicians located in rural or
HPSAs continue to receive
double-weight and report on no
more than 2 activities to receive
the highest score
Activity Inventory
CEHRT Bonus
Added 6 new Improvement Activities
Modified 5 existing Improvement Activities
Removing 1 existing Improvement Activity
Total of 118 Improvement Activities for 2019
Removed the bonus to align with the new Promoting
Interoperability scoring requirements, which no longer
consists of a bonus score component
59
MIPS Year 3 (2019) Final
Promoting Interoperability Performance Category
Basics:
25% of Final Score in 2019
Must use 2015 Edition Certified
EHR Technology (CEHRT) in
2019
New performance-based scoring
100 total category points
Reporting Requirements
Year 2 (2018) Final Year 3 (2019) Final
Comprised of a base,
performance, and
bonus score
Must fulfill the base
score requirements to
earn a Promoting
Interoperability score
Eliminated the base,
performance, and bonus
scores
New performance-
based scoring at the
individual measure level
Must report the required
measures under each
Objective, or claim
exclusions if applicable
60
MIPS Year 3 (2019) Final
Promoting Interoperability Performance Category
Basics:
25% of Final Score in 2019
Must use 2015 Edition Certified
EHR Technology (CEHRT) in
2019
New performance-based scoring
100 total category points
Objectives and Measures
Year 2 (2018) Final Year 3 (2019) Final
Two measure set options
for reporting based on
the MIPS eligible
clinician’s edition of
CEHRT (either 2014 or
2015)
One set of Objectives and
Measures based on 2015
Edition CEHRT
Four Objectives: e-
Prescribing, Health
Information Exchange,
Provider to Patient
Exchange, and Public
Health and Clinical Data
Exchange
Added two new measures
to the e-Prescribing
Objective: Query of
Prescription Drug
Monitoring Program
(PDMP) and Verify Opioid
Treatment Agreement
61
MIPS Year 3 (2019) Final
Promoting Interoperability Performance Category Point Value
Objectives Measures Maximum Points
e-Prescribing
e-Prescribing 10 points
Query of Prescription Drug Monitoring Program
(PDMP) (new)
5 bonus points
Verify Opioid Treatment Agreement (new) 5 bonus points
Health
Information
Exchange
Support Electronic Referral Loops by Sending Health
Information (formerly Send a Summary of Care)
20 points
Support Electronic Referral Loops by Receiving and
Incorporating Health Information (new)
20 points
Provider to
Patient Exchange
Provide Patients Electronic Access to their Health
Information (formerly Provide Patient Access)
40 points
Public Health and
Clinical Data
Exchange
Immunization Registry Reporting
Electronic Case Reporting
Public Health Registry Reporting
Clinical Data Registry Reporting
Syndromic Surveillance Reporting
10 points
62
MIPS Year 3 (2019) Final
Promoting Interoperability Performance Category
Basics:
25% of Final Score in 2019
Must use 2015 Edition Certified
EHR Technology (CEHRT) in
2019
New performance-based scoring
100 total category points
Scoring
To earn a score for the Promoting Interoperability
Performance Category, a MIPS eligible clinician must:
1. Use 2015 Edition CEHRT for the performance
period (90 consecutive days or greater)
2. Submit a “yes” to the Prevention of Information
Blocking Attestation
3. Submit a “yes” to the ONC Direct Review Attestation
4. Submit a “yes” for the security risk analysis measure
5. Report the required measures under each
Objective, or claim exclusions, if applicable
63
MIPS Year 3 (2019) Final
Promoting Interoperability Performance Category
Basics:
25% of Final Score in 2019
Must use 2015 Edition Certified
EHR Technology (CEHRT) in
2019
New performance-based scoring
100 total category points
Scoring
Year 2 (2018) Final Year 3 (2019) Final
Fulfill the base score
(worth 50%) by
submitting at least a 1 in
the numerator of certain
measures AND submit
“yes” for the Security
Risk Analysis measure
Performance score
(worth 90%) is
determined by a
performance rate for
each submitted measure
Bonus score (worth 25%)
is available
Maximum score is 165%,
but is capped at 100%
Performance-based scoring
at the individual measure
level
Each measure will be scored
on performance for that
measure based on the
submission of a numerator
and denominator, or a “yes
or no”
Must submit a
numerator of at least
one or a “yes” to fulfill
the required measures
The scores for each of the
individual measures will be
added together to calculate
a final score
If exclusions are claimed,
the points will be allocated to
other measures
64
Exclusions
e-Prescribing measure, if exclusion is claimed, 10 points will be distributed:
5 points to Support Electronic Referral Loops by Sending Health Information
5 points to Support Electronic Referral Loops by Receiving and Incorporating Health
Information
Support Electronic Referral Loops by Receiving and Incorporating Health Information, if
exclusion is claimed:
Redistribute 20 points to the Support Electronic Referral Loops by Sending Health
Information measure
Support Electronic Referral Loops by Sending Health Information measure - TBD
Public Health exclusions, if 2 exclusions are claimed:
Redistribute 10 points to the Provide Patients Electronic Access to Their Health Information
measure, if report yes for 2 measures or report 1 and claim 1 exclusion.
Promoting Interoperability
Scoring
65
MIPS Year 3 (2019) Final
Promoting Interoperability Performance Category Scoring Example
Objectives Measures
Maximum
Points
Numerator/
Denominator
Performance
Rate
Score
e-Prescribing e-Prescribing 10 points 200/250 80% 10 x 0.8 = 8 points
Health
Information
Exchange
Support Electronic
Referral Loops by
Sending Health
Information
20 points 135/185 73% 20 x 0.73 = 15 points
Support Electronic
Referral Loops by
Receiving and
Incorporating Health
Information
20 points 145/175 83% 20 x 0.83 = 17 points
Provider to
Patient
Exchange
Provide Patients
Electronic Access to
their Health
Information
40 points 350/500 70% 40 x 0.70 = 28 points
Public Health
and Clinical
Data
Exchange
Immunization
Registry Reporting
Public Health
Registry Reporting
10 points Yes
Yes
N/A 10 points
Total 78 Points
66
MIPS Year 3 (2019) Final
Promoting Interoperability Performance Category Scoring Example
Total Score
(from previous slide)
78 points
Calculate the contribution to
MIPS Final Score
78 x .25 (the category value) = 19.5
performance
category points
Final Performance Category
Score
19.5 points
out of the 25
performance category points
67
MIPS Year 3 (2019) Final
Promoting Interoperability Performance Category
Basics:
25% of Final Score in 2019
Must use 2015 Edition Certified
EHR Technology (CEHRT) in
2019
New performance-based scoring
100 total category points
Reweighting
Year 2 (2018) Final Year 3 (2019) Final
Automatic reweighting
for the following MIPS
eligible clinicians: Non-
Patient Facing,
Hospital-based,
Ambulatory Surgical
Center-based, PAs,
NPs, Clinical Nurse
Specialists, and
CRNAs
Application based
reweighting also
available for certain
circumstances
Example:
clinicians who
are in small
practices
Same requirements as Year
2, with the following additions:
Extended the automatic
reweighting for:
Physical Therapists
Occupational
Therapists
Clinical
Psychologists
Speech-Language
Pathologists
Audiologists
Registered
Dieticians or
Nutrition
Professionals
68
Final Rule for Year 3 (2019) MIPS
Additional Bonuses, Performance Threshold,
and Payment Adjustments
69
MIPS Year 3 (2019) Final
Complex Patient Bonus
Same requirements as Year 2:
Up to 5 bonus points available for treating complex patients based on medical
complexity
As measured by Hierarchical Condition Category (HCC) risk score and a score
based on the percentage of dual eligible beneficiaries
MIPS eligible clinicians or groups must submit data on at least 1 performance
category in an applicable performance period to earn the bonus
70
MIPS Year 3 (2019) Final
Performance Threshold and Payment Adjustments
15 point performance threshold
Additional payment adjustment for
exceptional performance bonus set at 70
points
Payment adjustment could be up to +5% or
as low as -5%*
Payment adjustment (and additional
payment adjustment for exceptional
performance) is based on comparing final
score to performance threshold and
additional performance threshold for
exceptional performance
Year 2 (2018) Final
30 point performance threshold
Additional payment adjustment for
exceptional performance bonus set
at 75 points
Payment adjustment could be up to
+7% or as low as -7%*
Payment adjustment (and additional
payment adjustment for exceptional
performance) is based on comparing
final score to performance threshold
and additional performance threshold
for exceptional performance
Year 3 (2019) Final
*To ensure budget neutrality, positive MIPS payment adjustment factors are likely to be increased or decreased by an amount called a
“scaling factor.” The amount of the scaling factor depends on the distribution of final scores across all MIPS eligible clinicians.
71
MIPS Year 3 (2019) Final
Performance Threshold and Payment Adjustments
Year 2 (2018) Final Year 3 (2019) Final
Final
Score
2018
Payment Adjustment 2020
>70
points
Positive adjustment greater than 0%
Eligible for additional payment
adjustment for exceptional
performance - minimum of additional
0.5%
15.01-
69.99
points
Positive adjustment greater than 0%
Not eligible for additional payment
for exceptional performance
15
points
Neutral payment adjustment
3.76-
14.99
Negative payment adjustment
greater than -5% and less than 0%
0-3.75
points
Negative payment adjustment of -5%
Final
Score
2019
Payment Adjustment 2021
>75
points
Positive adjustment greater than 0%
Eligible for additional payment
adjustment for exceptional
performance - minimum of additional
0.5%
30.01-
74.99
points
Positive adjustment greater than 0%
Not eligible for additional payment for
exceptional performance
30
points
Neutral payment adjustment
7.51-
29.99
Negative payment adjustment
greater than -7% and less than 0%
0-7.5
points
Negative payment adjustment of -7%
72
Quality Payment Program
Help & Support
73
Technical Assistance
Available Resources
CMS has free resources and organizations on the ground to provide help to clinicians
who are participating in the Quality Payment Program:
Learn more about technical assistance: https://qpp.cms.gov/about/help-and-support#technical-assistance
74
Session Title
Session #
Room #
Date
Start Time
End Time
Meaningful
Measures
#113
W307A
Wed., 2/13
10:00 a.m.
11:00 a.m.
Balancing
Value &
Burden: CMS
Electronic
Quality
Reporting
#199
W307A
Thurs., 2/14
8:30 a.m.
9:30 a.m.
CMS
Interoperability
Rule
#233
W307A
Thurs., 2/14
11:30 a.m.
12:30 p.m.
Additional CMS Education Sessions
75
Molly MacHarris, MIPS Program Lead, CMS
Elizabeth S. Holland, Senior Technical Advisor, CMS
Questions